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South African Law • Jurisdictional Corpus
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Kruger v Coetzee

Citation1966 (2) SA 428 (A)
JurisdictionZA
Area of Law
Law of Delict

Facts of the Case

Kruger was injured when Coetzee's vehicle collided with his. Kruger sued for damages based on Coetzee's negligent driving. The case required the court to define the test for negligence in delictual liability.

Legal Issues

  • Negligence
  • Reasonable person test
  • Standard of care
  • Foreseability
  • Preventability

Judicial Outcome

Kruger's claim succeeded. Coetzee was held liable for damages arising from his negligent conduct.

Ratio Decidendi

A person is negligent if a reasonable person in their position would have: (1) foreseen the reasonable possibility of harm; and (2) taken reasonable steps to prevent that harm. The test has two components: foreseeability and preventability. Both must be assessed objectively from the perspective of the reasonable person (diligens paterfamilias). Subjective factors like the defendant's inexperience or personal limitations are generally irrelevant.

Obiter Dicta

Data not available for this record

Legal Significance

This is the leading South African case defining negligence. It established the two-stage reasonable person test (foreseeability + preventability) that courts still apply today. The case is absolutely fundamental to understanding fault in delict and appears in virtually every law of delict exam. Every law student must be able to recite and apply the Kruger v Coetzee test.

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Camilla Jane McDowell v The Minister of Justice and Constitutional DevelopmentCase no. A 104/2007 (unreported, Cape High Court, 21 May 2007)
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